Powdered Corn Cobs (Cellulose) DP Number: 402046, 402312

PC Code: 100154 EPA File Symbol No.: 84889-E

Type of Review: Product Chemistry, Toxicology

1 

OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

MEMORANDUM

DATE: October 3, 2012

SUBJECT: Science Review in Support of Rode-Trol, Containing 90.0% Powdered Corn Cobs 

(33.3% Cellulose) As Its Active Ingredient. 

Decision Number: 447148

DP Number: 402046, 402312

EPA File Symbol Number: 84889-E

Chemical Class: Biochemical

PC Code: 100154

CAS Number: 9004-34-6 (cellulose)

Active Ingredient Tolerance Exemptions: Nonfood-use

MRID Numbers: 48433501-48433503, 48433506,

48533801-48533802, 48824701*not all MRIDs are 

associated with the DP numbers.

FROM: Angela L. Gonzales, Biologist

Biochemical Pesticides Branch

Biopesticides & Pollution Prevention Division (7511P)

TO: Leonard Cole, Senior Regulatory Specialist

Biochemical Pesticides Branch

Biopesticides & Pollution Prevention Division (7511P) 

ACTION REQUESTED

On behalf of Rode-Trol, LLC, E

x

ponent, Inc. requests registration of Rode-Trol, an end-use product 

(EP) containing powdered corn cobs (33.3% cellulose). The chemical is a new biochemical active 

ingredient. The proposed EP is intended for use as a rodenticide in commercial and residential indoor 

settings. In support of the proposed EP, the registrant submitted a proposed product label, Confidential 

Statement of Formulas (CSFs) dated 7/12/11, product chemistry data and information in MRIDs

48433501-48433402, 48533801 and 48824701 and mammalian toxicology data and information in 

MRIDs 48433503, 48433506 and 48533802.

RECOMMENDATIONS AND CONCLUSION
1. The product chemistry submission is ACCEPTABLE pending resolution of the deficiencies 

discussed below.

MRID 48433501-UPGRADEABLE MRID 48433502-UPGRADEABLE

MRID 48533801-ACCEPTABLE MRID 48824701-ACCEPTABLE

a. Refer to the Confidential Appendix (CA) below.

b. Refer to the CA below.

c. The active ingredient statement on the label must be revised as follows:

ACTIVE INGREDIENT:

Powdered Corn Cobs*...............................90%

OTHER INGREDIENT(S):...................... 10%

TOTAL: 100%

*Contains 33.3% w/w Cellulose 

d. Refer to the CA below.

e. The bulk density of the MP was provided to fulfill the density data requirement for the EP. Density

data for the EP should be provided and listed in box 7 on the CSF.

f. The rationale provided to satisfy the storage stability (OCSPP 830.6317) and corrosion characteristics 

(OCSPP 830.6320) is inadequate. Additional scientifically-sound rationale supported by references must 

be submitted or studies must be conducted. 

2. The mammalian toxicology submission is ACCEPTABLE.

MRID 48433503-UPGRADEABLE MRID 48433506-ACCEPTABLE

MRID 48533802-ACCEPTABLE

3. Nontarget toxicology data are not required for the EP at this time.

NOTE TO RAL:

1. In the “Ingredients” row on the data matrix dated 7/12/11, the applicant listed the active ingredient as 

mono- and di- potassium salts of phosphorous acid which must be revised.

2. Efficacy data were submitted to support registration of the EP but were reviewed by another science 

reviewer. Refer to the memoranda from C. Fuentes for more information.

STUDY SUMMARIES

Product Chemistry (MRIDs 48433501-48433502, 48533801 and 48824701)
Powdered Corn Cobs (Cellulose) DP Number: 402046, 402312

PC Code: 100154 EPA File Symbol No.: 84889-E

Type of Review: Product Chemistry, Toxicology

3

All data requirements have been satisfied with the exception of storage stability and corrosion 

characteristics. Physical and chemical properties data for the EP are summarized in Table 1 below. Data 

Evaluation Records (DERs) were not created for the submitted MRIDs. Refer to the CA below for more 

product chemistry information.

TABLE 1. Physical and Chemical Properties of Rode-Trol (40 CFR § 158.2030)

OCSPP 

Guideline Property Description of Result(PC 38-DD) MRID

830.6302 Color Light-brown/beige 48433502

830.6303 Physical State Solid pellet 48433502

830.6304 Odor Characteristic of hay 48433502

830.6313 Stability to Normal and 

Elevated Temperatures, Metals 

and Metal Ions

Not required for EP

830.6315 Flammability Flash point: 388oF (open cup); 396 oF (closed 

cup) (data are bridged from TGAI; inert 

components not expected to contribute 

significantly to flammability)

48433502

830.6317 Storage Stability Rationale is inadequate 48433502

830.6319 Miscibility N/A: not an emulsifiable liquid that will be 

diluted with petroleum solvents.

48433502

830.6320 Corrosion Characteristics Rationale is inadequate 48433502

830.7000 pH N/A: test substance is not soluble or dispersible 

in water

48433502

830.7050 UV/Visible Light

Absorption

Not required for EP

830.7100 Viscosity N/A: product is a solid 48433502

830.7200 Melting Point/Range Not required for EP

830.7220 Boiling Point/Range Not required for EP

830.7300 Bulk Density 28.0 lb/ft3

(data are for the MP and should be 

submitted for the EP)

48433502

830.7520 Particle Size, Fiber Length and 

Diameter Distribution

Not required for EP

830.7550

830.7560

830.7570

Partition Coefficient (nOctanol/Water)Not required for EP

830.7840 Water Solubility Not required for EP

830.7950 Vapor Pressure Not required for EP

Mammalian Toxicology (MRIDs 48433503, 48433506 and 48533802)